ML20210H822
| ML20210H822 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/07/1986 |
| From: | Dougherty F TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20210F162 | List:
|
| References | |
| DAP-7, NUDOCS 8702110480 | |
| Download: ML20210H822 (82) | |
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TITLE TRENDING AND GEERIC IMPLICATIONS EVALUATIONS NUMBER DAP-7 Revision Prepared Date Reviewed Date Approved Date o EsAid th/% Q4 %nI &l SPN' wk d rMrs W '=A i /uya QLq %g f %jn fQ sg 2 / /%' ,, j,,p 1
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l TABLE OF CONTENTS I
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section Eggt Cover Sheet ......................................... i Table of Contents ................................... 11 1.0 PURPOSE ........................................ 1
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2.0 SCOPE .......................................... 1 3.0 DEFINITIONS AND RESPONSIBILITIES ............... 2 4.0 INSTRUCTION .................................... 12 t
5.0 DOCUMENTATION .................................. 32 A
ATTACHMENTS A EXPLANATORY ATTRIBUTES MATRIX .................. A-1 i
B TREND EVALUATION ............................... B-1 C GENERIC IMPLICATIONS EVALUATION l
ENGINEERING EVALUATION ......................... C-1 D EXAMPLE LIST OF POTENTIAL ROOT CAUSES OR CAUSAL FACTORS .............................. D-1 E EXAMPLE QUESTIONS FOR EVALUATION OF POTENTIAL ROOT CAUSES OR CAUSAL FACTORS ........ E-1 F TREND EVALUATION FORM DAP-7-1 .................. F-1 G TREND EVALUATION LOG DAP-7-2 ................... G-1 H
SUMMARY
OF DAP-7 ............................... H-1 TN-85-6262/7 11
COMANCHE PEAK RESPONLE TEAM - DESIGN ADEQUACY PROCEDURE "O Number: DAP-7
Title:
TRENDING AND GENERIC IMPLICATIONS EVALUATIONS Revision: 2 1.O PURPOSE This procedure establishes acceptable methods for perform-ing two separate types of evaluations. They are: (1) identifying trends in DAP findings and External Source issues (including resolved External Source issues), and evaluating whether these trends are adverse, and (2) evaluating the generic implications of deficiencies, unclassified deviations, unclassified trends, and identi-fled adverse trends. The use of these methods or equiva-l'ont techniques for trending (such as completion of an Issue Resolution Report (IRR) that encompasses those DIRs covered in the IRR or are part of an adverse trend covered -
l in an IRR) will provide reasonable assurt.nce that trends or generic implications have been identified and evaluated.
2.0 SCOPE This procedure applies to DAP technical disciplines and the -
programmatic / generic implications discipline in trending
) and generic implications (including root cause) evaluations I of External Source issues and discrepancies identified I
during the DAP review of the design of CPSES. Equivalent techniques, such as an IRR, may be used if they are consistent with the requirements of Appendix E to the CPRT Program Plan. This procedure encompasses evaluations of identified adverse trends, unclassified deviations, unclassified trends, and deficiencies. This procedure does not encompass the overall program evaluation of the quality ld -
of the design of CPSES (see DAP-9). Attachment H is an O -
TN-85-6262/7
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, COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 IMPLICATIONS EVALUATIONS -
executive level summary of trending and generic implica-tions evaluations and their relationships with other DAP activities.
3.0 DEFINITIONS AND RESPONSIBILITIES 3.1 Definitions
,- 3.1.1 Trend As quoted from Appendix E of the CPRT Program Plan, "(a) trend is a set of related discrepancies (observations and/or deviations) having attributes that reflect a discernable commonality. Examples of possible commonali-
- ties include
o The individual, group or individuals, or organization performing the safety-related activity o The program requirements, procedures, or controls governing the performance of the safety-related activity.
In this procedure, a multidisciplinary trend is one that affects more than one discipline. This use of the term "multidisciplinary" is not limited to the multidisciplinary review activities in the DSAPs that deal with equipment r qualification, FMEA, flooding, fire protection, etc.
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- COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
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Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 IMPLICATIONS EVALUATIONS 3.1.2 Adverse Trend A trend is considered to be adverse if it ic determined that the identifien pattern or commonality is likely to have resulted in the occurrence of an undetected (safety-significant) deficiency in the affected area of design.
With respect to design, an adverse trend is programmatic in nature and is classified as a programmatic deficiency. A
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full safety-significance evaluation such as is prov dad in DAP-22 is not required, but may be conducted, to a ke a l[
determination that a trend is adverse.
3.1.3 Programmatic Deficiency A set of related design discrepancies that have been determined to constitute an adverse trend that is program-matic in nature. An adverse trend is referred to as a programmatic deficiency. A trend is considered to be adverse if it is determined that the identified pattern or commonality is likely to have resulted in the occurrence of an undetected safety-significant deficiency in the affected design area. A programmatic deficiency can include any
- identified design control program deviation meeting one or more of the following criteria
o Inadequacy of a design control program element such that substantive revision of the program, or other corrective action, is required to bring it into compliance with the regulatory require-ments, FSAR commitments, or other licensing commitments; or
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Page 3 of 36'
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TN-85-6262/7
. COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE p Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 g IMPLICATIONS EVALUATIONS o Fyte sive evaluation would be required to determine the effect on the quality of design.
b Programmatic deficiencies (like design deficiencies) are subject to evaluations of safety-significance, root cause, generic implications, and adequacy of corrective action.
. 3.1.4 Unclass.ified Deviation A deviation or set of deviations for which it has been determined that it is more practical to proceed directly to analyzing root cause and generic implications and specify-ing of corrective actions. A safety-significance evalua-tion will not be done for unclassified deviations because it would serve no useful purpose. Unclassified deviations are those related to areas in which reverification or redesign is being conducted. Unclassified deviations will be tracked as deficiencies in that root cause and generic implications evaluations will be done and corrective action will be evaluated. In areas where reverification or redesign is being performed, the assessment of root cause and generic implications is only for the purpose of l identifying potential problems in other design areas.
3.1.5 Trend Evaluation .
A process of developing and reviewing information (e.g.,
attributes) related to issues, discrepancies, observations, deviations, unclassified deviations, or deficiencies, that i* Y 2 fC.~. 7 ~ 1._ 1.
h 15-1262/7 Page 4 of 36
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2
- IMPLICATIONS EVALUATIONS is intended to identify any trend and to determine whether it constitutes an adverse trend.
4 3.1.6 Attributes A set of characteristics that describes an issue, discre-
- pancy, observation, deviation, unclassified deviation, or deficiency and can be used to identify a trend.
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3.1.7 Attribute Matrix A matrix that contains all or a subset of records (Discre-pancy/ Issue Resolution (DIR) Reports) in the DAP tracking system (deficiency, deviation, unclassified deviation, observation, discrepancy, issue, or any combination of these) and selected, relevant attributes that apply to each I
of the records included. Matrices with different sets of attributes are generated by sorting DIRs that exhibit those selected attributes.
3.1.8 Common Attribute l
l An attribute that is found by sorting of DIRs, or evalua-tion, to be a common characteristic of a set of issues, discrepancies, observations, deviations, unclassified deviations, or deficiencies. A common attribute exists when there are multiple DIRs that exhibit a particular attribute. A common attribute that relates to several DIRs or issues is an indication of a trend or pattern.
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, COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 l IMPLICATIONS EVALUATIONS 3.1.9 Generic Implication A reasonable likelihood that an issue or discrepancy (DIR) affects some aspect of design other than the specific instance in which the finding is identified.
3.1.10 Generic Implications Evaluation The process of reviewing programmatic deficiencies, unclassified deviations, unclassified trends, or design deficiencias identified or confirmed by the DAP to:
ld o Determine whether related design deficiencies exist, o Investigate the root cause or casual factors, and o Determine limiting boundaries of applicability of the deficiency under review.
In special cases, actions beyond those listed for any given classification may be warranted. For example, it may be considered appropriate to assess generic implications for a particular deviation or (non-adverse) trend.
3.1.11 Root Cause The cause or causal factors that contributed to a program-matic deficiency, unclassified deviation, unclassified trend, or design deficiency, i.e., why it occurred. A root
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cause may be determined during an evaluation by testing a hypothesis or by making a preliminary judgement subject to TN-85-6262/7 Page 6 of 36 l
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, I COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 O lMPLICATIONS EVALUATIONS confirmation. Root causes and causal factors and the extent of their applicability in design are based on objective evidence. They are confirmed and bounded by the findings of evaluations (what does exist) rather than by general statements of what could exist. In special cases, actions beyond thosa listed for any given classification may be warranted. For example, it may be considered appropriate to assess generic implications for a particular deviation or (non-adverse) trend.
' 3'. l .12 Safety Significance As quoted from Appendix E of the CPRT Program Plan:
" Safety-significant," for purposes of the CPRT Program, is defined to mean that the identified discrepancy, if uncorrected, would result in the loss of capability of the affected system, structure or component to perform its intended safety function.
For purposes of the CPRT Program, credit is not allowed for redundancy at the component, system, train -
i or structure level.
This definition, which is employed in the CPRT Prograin for purposes of sample expansion, is more restrictive than that.usually applied to the term " safety-signifi-cant" for regulatory purposes or in common parlance, in that it ignores redundancies that do exist in real life. (compara 10 CFR 50, Appendix A (Introduction,
" Single Failure"); 10 CFR 50,55 (e) (1) . ) Identifica-tion of a deficiency as " safety-significant" for purposes of the CPRT Program, therefore, is not l equivalent to a statement that, in fact, the deficien-cy, if uncorrected, would have resulted in unsafe operation.
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 lMPLICATIONS EVALUATIONS 3.1.13 Unclassified Trend A trend for which it has been determined that it is more practical to proceed directly to analyzing root cause and generic implications and specifying corrective actions. A safety-significance evaluation will not be done for unclassified trends because it would serve no useful purpose. Unclassified trends will be tracked as adverse
_ trends (programmatic deficiencies) in that root cause and generic implications evaluations will be done, and correc-tive action will be evaluated. In areas where reverifica-tion or redesign is being performed, the assessment of root cause and generic implications is only for the purpose of identifying potential problems in other design areas.
O 3.1.14 Primary Issue l
A DIR that is originated (or revised) to reflect all aspects of (1) duplicate External Source Issues ("E" type DIRs), (2) duplicate DAP-identified discrepancies that are found to have been entered in the DAP Tracking System ("D" typa DIRs), or (3) "E" or "D" type DIRs that are not duplicates but are related to a technical or programmatic design issue and are grouped into a single DIR. Related DIRs may be grouped as an input to an IRR, as documentation
, of a trend, or as a compilation of DIRs that facilitates evaluation, resolution, or closure, regardless of whether l the primary DIR is included in an IRR or a trend. A l
primary issue DIR that is the subject of an IRR may be l
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE O Number: DAP-7
Title:
TRENDING AND GENERIC IMPLICATIONS EVALUATIONS Revision: 2 classified as an unclassified deviation, a programmatic deficiency, or other classification as appropriate.
l 3.2 Resnonsibilities !
Responsibilities specific to this procedure tre as follows:
3.2.1 Generic Implications Coordinator o Establishes a program and methodology for (1) discipline-specific trend evaluations of observations, deviations, unclassified deviations, unclassified trends, or defi-ciencies (including External Source Issues) ld that apply to a single DAP discipline, and (2) multidisciplinary trend evaluations.
o Establishes a program and methodology for discipline-specific and multidisciplinary generic implications evaluations of programmatic deficiencies, unclassified deviations, unclassified trends, and design ld deficiencies. This constitutes investiga-tion of root causes and limiting boundaries of applicability.
o Reviews or manages reviews of results of i
trend and generic implications evaluations for consistency and potential effects in other disciplines.
o Manages the generic implications evaluation program and maintains DAP-7.
o Participates in determinations of adverse trends and root cause of multidisciplinary programmatic deficiencies, unclassified deviations, unclassified trends, and design ld deficiencies.
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l COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE f)
V Number: DAP-7
Title:
TRENDING AND GENERIC lMPLICATIONS EVALUATIONS Revision: 2 l j
l o Coordinates applicable programmatic consi-derations with the QA/QC Review Team or other TRT Review Teams through proper inter-faces.
o Maintains auditable files and documentation for multidiscipline trending and generic implications evaluations.
o Forwards evaluation results to the Design Adequacy Program Manager and Design Adequacy Program Review Team Leader for review, concurrence, or approval as appropriate.
o Provides apparent cross-discipline concerns to other disciplines, as applicable, based upon review of discipline-specific evalua-tions.
3.2.2 Discipline Coordinators o Conduct or direct trend evaluations and generic implications evaluations within their discipline to assess whether trends exist, whether trends are adverse, whether generic implications exist and whether the bounds and root causes of generic implications appear to be localized within the discipline. Identify those implications which may be cross-discipline in nature to the Generic Implications Coordinator and other potentially affected Discipline Coordinators.
o Participata in the determination of root causes of programmatic design deficiencies or unclassified trends within the disci-pline. ld o Modify or create new action plans as necessary to address generic implications identified by generic implications evalua-tions.
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. COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE e Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 I
IMPLICATIONS EVALUATIONS e
o Maintain auditable files and documentation for discipline-specific trend and generic implications evaluations, o Review and concur in evaluations done within-their discipline.
o Forward results of trend and generic implications evaluations including trending A forms, primary DIRs, etc., done within the 4D discipline to the Generic Implications coordinator for review and to the DAP i .
Manager and DAP Review Team Leader for
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review, concurrence, or approval as appro-priate. ,
1 3.2.3 Discipline Leaders / Reviewers o Perform, coordinat'e, and document trend evaluations and generic implications evaluations as assigned.
l 3.2.4 Design Adequacy Program Manager o Approves work assignments for portions of generic implications evaluations (including root-cause investigations) that appear to affect more than one discipline.
o Directs implementation of a generic implica-any case tions evaluation of special described in Appendix E of the CPRT Program Plan.
o Participates in determination of adverse trends (at his option), unclassified trends and root causes of DIRs (including primary DIRs) that require root cause evaluation.
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2
- IMPLICATIONS EVALUATIONS P l
! o Reviews and concurs in the results of trend t
! evaluations and generic implications evaluations.
4 3.2.5 Design Adequacy Program Review Team Leader (RTL) j o Participates in determination of adverse 4
trends (at his option), unclassified trends, i
and root causes of DIRs (including primary DIRs) that require root cause evaluation. k Approves the results of trend evaluations, i
o i
including unclassified trends, and generic ld implications evaluations, and submits results to the SRT for review as required.
o Assists other non-QA/QC RTLs as requested in conducting root cause and generic implica-tions analyses.
4.0 INSTRUCTION
- These instructions provide requirements that shall be met i
in conducting trend evaluations per this procedure or as part of evaluations that lead to Issue Resolution Reports and generic implications evaluations. Each of these types of evaluations or equivalent evaluations for trends as part of Issue Resolution Reports shall be conducted by a specific DAP discipline for concerns that apply to that discipline, or by the Programmatic / Generic Implict.tions (PGI) discipline for portions of those concerns that affect more than one discipline. Figure 1 shows the relationships of trend and generic implications evaluations with discre-pancy classification, safety significance evaluation, corrective action evaluation, and closure. Attachment H is O TN-85-6262/7 Page 12 of 36
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EXTERNAL DIR , IR/DIR , DIR SELF.lNITIATED SOURCE ISSUES -
lDENTIFIED '
EVALUATION REVIEW D AP.2 1 :
DUPLICATE IR/DIRs TRANSFERRED TO DAP.2 EVALUATION; ATTRIBUTES PROJECT lDENTIFIED IDENTIFIED ISSUES DAP.2/ ACTION PL AN5 UNste5TANTIATED I 1i TREND
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. CLA IFIED C 7 LE Ll DAP.2 DAP.7 DEVIATION UNCLAS$1FIED 5AF Y DEVIATION DEVIATION ISSUE RESOLUTION cg p A CE m
- REPORT EVALUATION DAP.22 DAP.8 ,
, DEFICIENCY TR TREND EVALUATION @
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. 1 p ROOT CAUSE/CEffRIC A N SE
, TREND IMPLICATIONS
& EVALUATIONS 3
- DAP.7 'UNCL A551.
LlulTINGBOUNDARIES g FIED ,
TRENDS AND ROOT CAU5E h
- "U CORRECTIVE ACTION EVALUATION D e .ro
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- CLOSURE FIGURE I INTERRELATIONSHIPS OF DAP ACTIVITIES AND PROCEDURES O DISCREPANCY CLASSIFICATION, SAFETY SIGNIFICANCE EVALUATION TRENDING, GENERIC IMPLICATIONS, CORRECTIVE ACTION, AND CLOSURE REV.2 TN-SS-6262/7 Page 13 of 36
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 IMPLICATIONS EVALUATIONS i
an overview that summarizes these relationships, and trending and generic implications evaluations. This attachment is for information only, and should give those
- not directly involved in trending.and generic implications i
sufficient understanding of these evaluations to allow them to carry out interfacing activities without specific i~
training in DAP-7. Figure 3 ,of DAP-2 is a more detailed chart that shows these activ'ities in the context of the flow of Discrepancy / Issue Resolution (DIR) reports within the DAP. ,
4.1 Trend Evaluations
! Each DAP technical discipline shall perform trend evalua-l tions described in, or - equivalent to this ^section on information and findings that are identified within the i review activities of that DAP discipline'. The Di'scipline coordinator shall determine when such evaluations will be performed. Trend evaluations of information and aspects of findings that may reasonably affect more than one technical discipline shall be performed under the direction of the Programmatic / Generic Implications Coordinator, who shall determine when such evaluations shall be performed. Addi-tionally, the Programmatic / Generic Implications Coordinat'or may elect to initiate cross-discipli,ne trending based on the recommendations of findings of Discipline Coordinators who suspect a potential multidisciplinary trend. Normally, the programmatic / Generic Implications Coordinator will initiate multi- or cross-discipline trending by providing each Discipline Coordinator with the appropriate s' ort o.f TN-85-6262/7 Page 14 of 36 i-rr -ww w e- --9 -r e----+-----.--g-w,g ,------,% ---., y -.- .- -
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEGUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 IMPLICATIONS EVALUATIONS DIR's. Each Discipline Coordinator will provide the initial study for trend identification and evaluation for the discipline specific portion of the potential multi-discipline trend. g The decision criteria that will be used to determine when trend evaluations shall be conducted shall be included in appropriate discipline instructions. The purpose of a
. trend evaluation is to determine whether a trend exists and
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whether an identified trend is adverse. Attachment B provides step-by-step instructions for performing a trend evaluation and documenting it on Attachment F (from DAP 1) in accordance with these instructions. Departures from
- this guide, such as conducting an IRR that meets the intent l
of trend identification and evaluation, shall be justified and documented on form DAP-7-1 and approved by the Disci- ld j pline Coordinator or Programmatic / Generic Implications coordinator, as appropriate. His signature on the form indicates his approval of any such exceptions.
4.1.1 Input Information During the course of implementing the DAP within each discipline, design-related discrepancies may result from:
(1) identification through the self-initiated DSAP reviews, (2) confirmation in evaluations of open External Source
- Issues, or (3) classification of External Source Issues that had been closed by an external source. A Discre-pancy/ Issue Resolution report (DIR) per DAP-2 will be generated or. revised (if a primary DIR exists) to track lh TN-85-6262/7 Page 15 of 3E
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING ANb CENERIC Revision: 2
% IMPLICATIONS EVALUATIONS
, i these discrepancies. During reviews conducted within the discipline, the attributes of each discrepancy shall be s determined and documented on the DIR report to the extent reasonable to describe relevant information such as what,
, whera, when, why, who, and how, regarding the discrepancy.
Information that indicates a possible multidisciplinary trend shall be referred to the PGI discipline. This
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information (1) could be contained in Issue Records or DIRs,' (2) could result from a discipline-specific trend evaluation that identified an adverse trend (programmatic deficiency) that could logically affect other disciplines, or (3) could result from a discipline-specific generic implications evaluation that indicates that a problem is not limited to that discipline but could ' likely have renulted in safety-significant deficiencies in other l
disciplines.
4.1.2 Trend Attributes The attributes for identifying and evaluating trends are:
o Design discipline o Design organization s o Design activities l o system, structure, or component o classification, status and type of issue o Potential safety significance (if identi-fied)
TN-85-6262/7 Page 16 of 36 l
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE O Number: DAP-7
Title:
TRENDING AND GENERIC IMPLICATIONS EVALUATIONS Revision: 2 o Root cause (if identified) o Potential generic implication (if identi-fied) o Nature of the problem or technical issues (e.g. , IRR subject)
I o Review topic (group of HDAs) o Homogeneous design activity (HDA).
Within these attributes, an additional tier of entries that could be relevant to each issue, or DIR evaluated, have been developed. These entries in each attribute are Level II subattributes. A third tier within some subattributes has been developed to describe and characterize the Level II attributes as necessary. The Generic Implications coordinator shall develop a list of attributes, sub-i attributes, and amplifying information. Any major revi-sions of Attachment A will be incorporated by procedure revision.
l L 4.1.3 Trend Recognition Reviewers shall conduct trend evaluations using information in Issue Records and "D" type DIRs related to the self-initiated portion of the DAP. Information in evaluations and other documents generated within the DAP and contained in DAP files may also be used. Reviewers may identify trends manually or may use computer-assisted sorts of DIRs to identify relationships among the data. Duplicate Issue Records of the same observation (such as those that report O TN-85-6262/7 Page 17 of 36
r-m COMANCHE PEAK RES?ONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: . DAP-7
Title:
TRENDING AND GENERIC Revision: 2 O lMPLICATIONS EVALUATIONS l
the same issue in different parts of one External Source document or in different External Source documents) are not multiple observations and shall be counted as a single observation for trending purposes. DIRs that are related to the same technical or programmatic issue may also be l combined into primary issues, for example during develop-ment of DAP Issue Resolution Reports (IRRs). These related issues will be transferred to primary issues per DAP-2, and the primary issues, in addition to individual related issues, will be used in trend evaluations. Unsubstantiated
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issues, and issues transferred to another Review Team, will not be used in trend evaluations or generic implications l[
evaluations.
A trend shall be identified if a common attribute or set of
- attributes is found among a number of issues, observations, deviations, unclassified deviations, and deficiencies, as l defined in Section 3.1.1. The distribution of DIRs b exhibiting these attributes may indicate a possible causal relationship. Due to the broad scope of the DAP, it is expected that a trend that is programmatic will be indi-cated by several DIRs that are related to a single issue, or exhibit the same attribute of the trend. Although final trends will be based on DIRs with final classifications, trending may be done also on issues and discrepancies after
- entry in the DAP tracking system but before final classi-fication. Final decisions as to existence and adversity of trends will be based on final classifications of DIRs.
i TN-85-6262/7 Page 18 of 36 l
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 IMPLICATIONS EVALUATIONS Reviewers may conduct trend reviews to gain information concerning their discipline, review topic, HDA, etc. For example, a reviewer may trend information on one or more checklist attributes. In the event that such trend reviews are conducted, they are considered to be equivalent to trending described in this procedure, and each shall be documented or referenced on a form DAP-7-1. Trend reviews,
, if performed, should be documented as part of an appro-
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priate engineering evaluation or Issue Resolution Report.
If a trend is identified through a trend review, the determination of whether it is adverse should also be documented in the engineering evaluation or Issue Resolu-tion Report. DIRs shall be written, or primary DIRs revised, for any identified trends (whether found to be adverse, non-adverse, or unclassified) and shall be pro-d ceased in accordance with DAP-2.
. After a trend is identified, the trend shall be evaluated to determine whether it is adverse and programmatic in -
nature after consideration of the requirements of 4.1.4 or 4.1.5 as appropriate.
4.1.4 Trends in Discrepancies Classified only as Observations For trends found in discrepancias and External Source Issues classified only as observations, expansion of the DAP scope of review should not be performed to determine whether similar observations could be found. In this case, TN-85-6262/7 Page 19 of 36
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Q Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 V IMPLICATIONS EVALUATIONS the reviewer should proceed directly to the trend evalua-tion described in 4.1.6.
4.1.5 Trends in Discrepancies Classified as Observa-tions and Deviations I For trends indicated in discrepancies that include devia- ,
l tions, an investigation for the existence of similar ,
deviations shall be considered. The following action shall be taken within the appropriate technical disciplines to determine whether similar deviations exist elsewhere.
o Decide how to determine whether similar deviations exist if they have not already been identified. The method to make this O determination may be to reuse an existing checklist, or part of a checklist that is sufficient to detect a deviation if it exists in the area being reviewed.
o Determine from the project whether similar deviations had been identified in the past.
This could have been documented in 50.55(e) or Part 21 reports to the NRC or in Project internal reports such as TDDRs, ECNs, TDRs, NCRs, etc. (50. 55 (e) and Part 21 reports will be documented as "T" type DIRs per DAP-2 in the same format as DAP DIRs, to enable direct comparison of these reports to DAP deviations. Other project reports may also he documented by the DAP in "T" type DIRs for comparison purposes only).
o Based on the characteristics of the devia- ,
tion in the trend, determine whether, and if so, where else the deviation could logically exist.
o Decide what, if any, aspect of design activities should be examined further in O TN-85-6262/7 Page 20 of 36
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1 COMANCHE PEAK RESPONSE. TEAM - DESIGN ADEQUACY PROCEDURE ,
I Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 IMPLICATIONS EVALUATIONS looking for other deviations that could be part of the same trend. This may be a ,
review within the Homogeneous Design '
Activity (HDA) in which the deviation being evaluated was found, within a related HDA or review topic, or within an unrelated HDA, i but in which a deviation in the same trend could logically exist.
4.1.6 Trend Evaluation For a trend to ' be programmatic, multiple instances of observations or deviations should relate to a design -
process or design control process, or other programmatic aspect of design. This can include a process, procedure, practice, work activity, methodology, or similar program-matic aspect of design. This part of the trend evaluation will determine whether the observations or deviations that make up the trend indicate a relationship to one or more processes. Due to the nature of the information used to detect trends, it is expected that trends identified will generally be programmatic.
l l For a trend to be adverse, it must be likely that undetect-ed safety-significant deficiencies exist in the area (e.g.,
f HDA, review topic, design activity) affected by the trend.
The evaluation of a trend for adversity shall be based on engineering judgment as to whether undetected safety-
! , significant deficiencies related to the trend are likely to exist. The details of this evaluation and the scenario or conditions that cause the trend to be considered adverse shall be documented by the reviewer on form DAP-7-1 or its attachments, or in the engineering evaluation or IRR tha't iO TN-85-6262/7 Page 21 of 36
. . . .. .~
. COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
. Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 IMPLICATIONS EVALUATIONS documents the ~a dverse trend. A safety-significance evaluation (per DAP-22) is not required, but could be done to decide whether a trend is adverse. Regardless of f documentation method (i.e., Form DAP-7-1 and attachments, Form DAP-22, or specific words in an IRR) sufficient justification of the trend identification and evaluation of safety significance (whether safety significant or not b
safety significant) must be provided for reviewers to
~
. support the decision. The decision as to whether a trend is adverse shall be based on a consensus of involved reviewers and DAP management, up to and including, the Review Team Leader. ~
l If it is determined that an identified trend (documented either on an IRR or Trend Analysis) is to be " Unclassified" l along with its associated DIR being an " Unclassified Trend," safety significance need not be justified.
However, a Root Cause and Generic Implications Evaluation in accordance with this procedure is required.
If the trend evaluation indicates that the trend is' l adverse, the DIR that documents the trend (possibly a primary DIR) shall be classified as a programmatic defi- l ciency per DAP-2. The review scope shall be expanded, when required by DAP-3, if additional reviews are needed to l confirm that the trend is adverse. If the trend has been determined as adverse, guidance related to IRRs should be followed in deciding whether more reviews are necessary if j the trend is identified as part of an IRR.
l TN-85-6262 /7 Page 22 of 36
. COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE i
_ Number: DAP
Title:
TRENDING AND GENERIC Revision: 2 IMPLICATIONS EVALUATIONS 1
Unclassified trends shall be subject to a root cause/ gen-eric implications evaluation.
If the trend is not adverse, a DIR (closed observation) shall be written per DAP-2 to describe the trend and indicate that it is nonadverse. If the trend evaluation indicates that the trend identified in Section 4.1.3 does j . not actually exist, this result shall be documented on form DAP-7-1.
If the adverse trend is multidisciplinary, its multidis-ciplinary aspects shall be subject to a multidisciplinary I
generic implications evaluation. If the adverse trend appears limited to a single discipline, the trend shall be subject to a discipline-specific generic implications '
evaluation.
4.2 Generic Imolications Evaluation l
The purpose of a generic implications evaluation is to evaluate the root cause or causal factors and generic implications (limiting boundaries of applicability) of discrepancies that require a generic implications evalua-tion. A discipline-specific generic implications evalua-tion shall be performed for design deficiencies, un-classified deviations, programmatic deficiencies, and unclassified trends that appear to be limited to a specific discipline. (Note: Special cases may exist where root cause and generic implications evaluations are warranted d
TN-85-6262/7 Page 23 of 3d
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 O\ IMPLICATIONS EVALUATIONS for design deviations or nonadverse trends. Discipline Coordinators shall inform the RTL by memo of any such special cases identified by themselves or their staffs.
The RTL shall inform the SRT of such potential special cases and shall forward any documentation sent to or received from the SRT on this subject to the DAP files for appropriate filing. If such a special case root cause and generic implication is authorized, it shall be conducted in
~
accordance with DAP-7 unless otherwise directed in writing by the RTL.) If more than one discipline appears to be
'a'ffected, a multidisciplinary generic implications evalua- , ,
tion shall be performed for multidisciplinary aspects of the issue. Attachment c provides step-by-step instructions for performing a generic implications evaluation and documenting it in the form of an engineering evaluation.
Departures from this guide shall be justified and document-ed in the evaluation, and approved by the discipline coordinator (signified by his approval signature on the engineering evaluation cover sheet) . For example, if root cause or limiting boundaries of applicability are obvious, there is not need to formulate and test hypotheses to find those answers that are already known.
In design areas such as piping / pipe supports and cable tray and conduit supports, redesign or reverification programs are being performed to provide confidence that the final design and hardware configurations will be adequate.
Because of the comprehensive nature of the corrective action, the focus of generic implications evaluations in areas undergoing " redesign or reverification shall be to l TN-85-6262/7 Page 24 of 36 I
e
, , , - , , - - - - - . , , , - - - - - - - - - , - - - - , - - - - - , - - - - , - - - - - ~ , - - - - - - - - - - ' - - - - - ~ ~ - - - - - - - -
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7 O
Title:
TRENDING AND GENERIC IMPLICATIONS EVALUATIONS Revision: 2 determine whether unclassified deviations or unclassified trends that appear to have contributed to the overall need A for hardware modifications, have generic implications outside these design areas. Accordingly, within these j design areas, identification of root causes of unclassified .
deviations or unclassified trends is only for the purpose ld of determining whether the same root causes exist outside these design areas.
i .
4 -
4.2.1 Preparation of Engineering Evaluation An engineering evaluation of root cause and generic implications of design deficiencies, unclassified devia-tions, unclassified trends, and programmatic deficiencies shall be prepared in accordance with Attachment C. It ld shall include the following elements or justify those elements not included:
o Identification of relevant design attributes -
o Method of evaluation for generic implica-
- tions o Collection of infcraation and objective evidence o Investigation of root cause o Determination of the limiting boundaries of applicability.
These elements are addressed in separate sections below.
i 4
TN-85-6262/7 Page 25 of 3E
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y , ,, ..-,.-.--~,,-,-..v, -
, COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
, Numben DAP-7
Title:
TRENDING AND GENERIC Revision: 2 IMPLICATIONS EVALUATIONS 4.2.2 Identification of Relevant Design Attributes Attributes relevant to the programmatic deficiency, unclassified deviation, design unclassified trend, or l[
deficiency being evaluated for generic implications shall be selected. The engineering evaluation shall document the basis for selection of relevant design attributes.
Attachment A lists examples of design attributes from which relevant attributes may be selected; they are based, in l part, on ANSI N45.2.ll. Other attributes not listed in Attachment A may also be used, such as HDAs and review topie:s listed in the DSAPs. The level of detail of selected attributes may vary, depending on the nature of the evaluation, but the level of detail shall be sufficient for purposes of evaluating generic implications, finding 1 the limiting boundaries of generic implications, and investigating root cause or causal factors. Discipline-specific generic implications evaluations may select other
, appropriate attributes such as those- contained in disci-i pline-specific checklists. These attributes shall be those whose evaluation would be sufficient to confirm whether or not generic implications exist and, if so, to identify their limiting boundaries and investigate their root causes or casual factors. These attributes should characterize to the extent reasonable the what, where, when, why, who, and how of the design deficiency, unclassified deviation, unclassified evaluated.
trend, or programmatic deficiency being ld i
'l TN-85-6262/7 Page 26 of 36 i
. COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
- Nurnber: DAP-7
Title:
TRENDING AND GENERIC Revision: 2
- l IMPLICATIONS EVALUATIONS 4.2.3 Method of Evaluation for Generic Implications The method of evaluation shall include consideration of the following
i o Formulation . of a hypothesis of one or more generic implications, root causes, and limiting boundaries of applicability I o Determination of the type of information
{ _ needed to test each hypothesis (e.g., which
' attributes need to be evaluated , in which design activities, and what types of errors associated with these attributes will prove or disprove the hypothesis) o Identification of techniques to be used to 2
gather information (e.g., repeat part of a discipline-specific checklist, interview
- people, review project records, analyze i other DAP findings or documentation in the discipline, etc.)
o Identification of sources of informa-tion to be reviewed to test each
- hypothesis (e.g., what records or system of records, what organization, group, person, HDA, or review topic)
J i o If additional design work needs to. be
! reviewed, basis for selection of additional reviews that will test the hypothesis o Development of decision criteria to be used
- in proving or disproving the hypothesis
. o Justification that the hypothesis is
!~ adequate, and that the method of analysis satisfies necessary and sufficient con-ditions needed to prove or disprove the hypothesis TN-85-6262/7 Page 27 of 36 v.re---gw-,-.~,.r--,-,p.. , , - . , -y,g,,an_,,,-n-.,
i i
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEGUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 O IMPLICATIONS EVALUATIONS o Development of the type and level of detail of documentation needed to support conclu- -
sions (generic implication and root cause) of the evaluation (e.g. , engineering evalu-ation, discipline-specific checklist completion record, DIR generation and revision, etc.).
4.2.4 Collection of Information and objective Evidence
~
The content and source of information needed to test a
, hypothesized generic implication, root cause, or boundary of applicability should be identified. Techniques for
- collecting this information may include checklists, interview questions, written requests, DAP or project record reviews, or other appropriate methods.
To the extent reasonable, the input information for the conclusions of the evaluation shall be objective evidence.
The techniques used to gather information should guide DAP reviewers to this objective evidence. Therefore, informa-tion that does not constitute objective evidence shall not be used as a sole source of information to draw conclusions as to the validity and proof of a hypothesis. This restriction is intended to preclude reliance on inputs of personal opinion, recollection, hearsay, or bias, as a basis for DAP conclusions.
4.2.5 Investigation of Root Cause Investigation of root causes or casual factors of design deficiencies, unclassified deviations, unclassified trends ld O T.-..-.2 2,> Page 2. of 2e
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
- O Number: DAP-7
Title:
TRENDING AND GENERIC IMPLICATIONS EVALUATIONS Revision: 2 or programmatic deficiencies shall be a systematic approach that is described in the engineering evaluation. A list of potential root causes or causal factors and a checklist of
' questions that may be appropriate are Attachments D and E, respectively, of this procedure. If the root cause or causal factors are evident (or obvious) as a result of evaluations of programmatic deficiencies, unclassified deviations, unclassified trends, or design deficiencies, ld i .
the methods used to reach that conclusion shall be documen-l- ted in the engineering evaluation, and no additional
! investigation of root cause is needed.
ll l The determination of root cause shall be accomplished by l consensus of DAP management, including the Review Team Leader, DAP Manager, and appropriate Discipline Coordina-l tors, discipline leaders and reviewers.
Instances may arise in which a root cause may not be identifiable or cannot be confirmed even though a set of DAP findings may exhibit similar errors. In this instance, the errors will be resolved in accordance with DSAPs and controlling DAP procedures. The investipation conducted to determine a root cause shall be documented in the engineer-ing evaluation which shall state that a root cause could not be confirmed.
O 7$1-8!. ~62 62 /7 Page 29 of 36
. _ _ . _ - _ - . .- . . - . = _ . . _ - _ _ .
j . COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 lMPLICATIONS EVALUATIONS l 4.2.6 Determination of Limiting Boundaries of Applica-i bility
- The method of determining the limiting boundaries of applicability of a generic implication shall be described in the engineering evaluation. This determination should be based on reviews that address to a reasonable extent whether and, if so, where else in design the same design deficiency, unclassified deviation, unclassified trend, or ld
- - program
- natic deficiency was likely and was found to exist.
Boundaries may be established using techniques based on either deductive or inductive logic, or a combination
- thereof. These approaches are explained in Attachment C.
I The determination that limiting boundaries have been found shall be based on judgment that potentially affected areas
- have been investigated sufficiently to identify the generic implication if it exists. The bases of this determination shall be substantiated by documentation in the engineering evaluation.
I
! 4.2.7 Conduct or Revision of the Engineering Evaluation The engineering evaluation of root cause and generic implications shall be conducted or revised in accordance with Attachment C, or equivalent format, provided all equivalent information is included. After completion of the evaluation, revisions may become necessary; for example, to revise hypotheses, to reflect additional information or to modify evaluation techniques. Such changes shall be documented in a revision to the engineer-TN-85-6262/7 Page 30 of 36
.; i i '
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEGUACY PROCEDURE Nsmber: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 IMPLICATIONS EVALUATIONS ing evaluation. subject to the instructions of Attachment C
- or DAP-8, as applicable.
i 4.3 Anoroval of Trend Evaluations and Generic Innlications Evaluations 4.3.1 Trend Evaluation
" After the trend evaluation (form DAP-7-1) has been prepared (including consensus decision-making as to adversity) and signed by the reviewer, the Discipline Coordinator and DAP Manager shall review and sign the form when they are l satisfied with it. The Discipline Coordinator shall ensure that appropriate DIR forms are prepared (or revised if a I,
4 primary DIR exists) in accordance with DAP-2. Depending upon the results of the trend evaluation, DIRs may he required to document as o conclusion that a trend is a programmatic deficiency; or
- o conclusion that a trend is a nonadverse observation. .
o conclusion that a trend is an unclassified trend.
ld If no trend is determined to exist, no DIR is required.
The Review Team Leader approves trend evaluations.
After concurrence and approval as required above, the evaluation shall be assigned a control number in accordance with section 5.3.
O TN-85-6262/7 Page 31 of 36
. COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2
, IMPLICATIONS EVALUATIONS 4.3.2 Engineering Evaluations for Collective Trend Evaluations Upon completion of all trend evaluations within each DAP discipline, each discipline shall prepara an engineering evaluation that documents all trending done in a DAP discipline. This evaluation shall be reviewed and signed, indicating concurrence, by the DAP Coordinator and DAP Manager. These engineering evaluations shall be approved
- by the Review Team Leader. Engineering ovaluations shall be assigned control numbers per DAP-8.
i 4.3.3 Generic Implications Engineering Evaluations l These evaluations shall be reviewed, concurred in, i - approved, and assigned control numbers as stated in Section 4.3.2.
5.0 DOCUMENTATION 1
5.1 Documentation of Tre'nd Evaluations and Generic Inclications Evaluations i Trend evaluations and generic implications evaluations shall be documented in a manner that explains what was done, what the results and conclusions were, what their bases were, and who reviewed and approved the evaluation.
a TN-85-6262/7 Page 32 of 36
j .
t COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
^
O Number: DAP-7
Title:
TRENDING AND GENERIC IMPLICATIONS EVALUATIONS Revision: 2 Each trend evaluation shall be documented on a completed form DAP-7-1 and, as necessary, supporting attachments.
Documentation shall include:
f o Form DAP-7-1 and any continuations of text
- from the blocks of information in this form o The results of sorts / searches of attributes data that support the trend evaluation
, conclusion i
o
_ DIR numbers of DIRs that are part of a trend if a trend is found o The number of the primary DIR written if a trend is found l o The bases of a conclusion that a trend exists and that it is nonadverse or adverse.
lO As an alternative to the above requirements, an IRR that contains the above information is acceptable, provided that t form DAP-7-1 is prepared, and references the sections in the IRR that address trend identification and trend evaluation for safety significance.
b l
Documentation of each generic 4.mplications evaluation shall include use of the forms, structure, and applicable parts of engineering evaluations (DAP-8) as described in Attach-ment c of this procedure. The evaluation format may be varied as appropriate to the scope of the evaluation
- provided that all required information is included.
Supporting documentation, that consists of information and objective evidence of whether generic implications exist, and any discipline-specific checklists used in the evalua-O TN-85-6262/7 Page 33 of 36
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE O Numiser: DAP-7
Title:
TRENDING AND GENERIC IMPLICATIONS EVALUATIONS Revision: 2 tion, shall be incorporated in, or appended to, the engineering evaluation.
Documentation of all trend evaluations done collectively within each DAP discipline shall consist of one trending engineering evaluation per discipline. This evaluation shall explain the process used for trend evaluations, list trends found and the number of trend evaluations done, and shall be sufficient to justify the conclusion with reason-able assurance that no adverse trends remain undetected in the scope of activities reviewed by that discipline. Each individual trend evaluation form DAP-7-1 completed by the I discipline, with attachments, shall be attached to the trending engineering evaluation. The requirements of DAP-8 regarding approval, modifications and revisions, shall apply to the trending engineering evaluations.
5.2 Documentation of Trends and Generic Innlications Adverse trends shall be documented as programmatic defi-ciencies in primary Discrepancy / Issue Resolution (DIR) reports, marked " adverse trend," tracked per DAP-2, and processed according to DAP procedures and requirements.
Unclassified trends shall be tracked as programmatic deficiencies. Nonadverse trends shall be documented in primary DIR reports per DAP-2 as observations marked "nonadverse trend." No DIR is needed if a trend evaluation results in a conclusion that no trend exists. Root causes and generic implications shall be documented in the l appropriate portions of Discrepancy / Issue Resolution O,,. TN-85-6262 /7 Page 34 of 36 l
-_m.,._ ., ywe,.,,__m_w,w -
--.m_ .,_.y.
r COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 O IMPLICATIONS EVALUATIONS i
reports per DAP-2 for the primary issues and discrepancies which require these portions to be filled in. Supporting documentation of root causes and generic implications shall I
be contained in engineering evaluations per this procedure.
5.3 Idgntification Upon identification of a potential trend, the trend evaluation shall be assigned a control identification ld
) .
l~ number by the DAP Manager or his designated representative l as follows:
' DAP-TE-XXX-YYY o 9 Sequential Number in the Discipline Discipline (per Attachment C of DAP-8) i This identification number, revision number, and date shall be entered into a Trend Evaluation Icg (Attachment G - Form l DAP-7-2, Rev. 1) maintained by each Discipline Coordina-tor. Trend evaluation forms may be revised during the DAP to reflect new information, and ultimately the final classification of all DIRs in each trend.
i Engineering evaluations that address trends and root cause/ generic implications evaluations shall be identified per DAP-8.
l TN-85-6262/7 Page 35 of 36 I
- - - . - - , . - -,,-n.- -,--, -,--- ~ . ---
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 2 IMPLICATIONS EVALUATIONS 5.4 Retention A copy of each final evaluation shall be maintained and filed by the DAP Manager or his designated representative in accordance with DAP-14.
j 5.5 Revisions
- _ Revisions to evaluations may be required to modify evalua-t, ion methods, add, clarify, correct'information, or reflect
[ final classifications of DIRs. Revisions shall be pre- ,
f pared, reviewed, and approved in the same manner as the
! appropriate type of original evaluation, and shall comply l with the applicable provisions of DAP-8 regarding revised, voided and superseded evaluations.
1 TN-85-6262/7 Page 36 of 36 l
.. I ATTACWENT A 4
- REPIANAT0tf ATTRISIFFES NATRIE
- LavEL I 12 VEL II 1275L III
- 1.0 Destas Discipline 1.1 Mechanical Systems and Componente Analysee i
Fluid j Focilities Piptog Pump and volve operatability 1
I Radiation protection 1.2 Electrical, Instrentation and Electric power equipment Control Electric power systese Electric cabling Electric equipment layout
,) I6C control rose layout Equipment quellfication Fire protection
- 1.3 F1 ping med Pipe Supporte Piping analyets j Support deelse i
Interface control i
i 1.4 Civil / Structural Cable trays / supports l Conduite and supports
- Structural steel i
Concrete deelge NVAC supports Seismic analysis i
Other supporte seismic Cap
- Structural i,
t l
- 1
) -
j .
TN-85-6262/7 A-1 i
)
I
m , .
ATTACBENT A E1F1JWATOET ATTRIBUTES HATR11 *
(Castimmed) 12 VEL I 12 VEL II 1.EvtL III 1.0 Desige Discipline 1.5 Fregrammetic/Ceneric laplicottene Moltidisciplisery (coetteved) Discipline-specific 1.6 Other 1.7 All 2.0 Desige Orgeelsetten 2.1 TUCCO (TUS1) 2.15 ANCO 2.2 TUCCO Weclear Easiseeriet (TNE) 2.16 CTCNA 2.3 CFFE 2.17 CCL 2.4 Cibbe & Mill 2.10 Sergeet & Leedy 2.5 weettegheese (eetside MSSS Scope of Sepply 2.19 Eyn 2.6 ITT Criesell 2.20 ssac 2.7 NFSI 2.8 PSE 2.9 Ebseco 2.10 Stees & Webster 2.11 Impe11 2.12 tehesen 2.13 DeLevel .
2.14 menom TN-85-4262/7 A-2
t ATTA W SNT A .
REP 1AAANRY ATTR13WTts lehTRIE (Contiemed) uvus. I tavat it tavat. It!
3.0 Destga Activity 3.1 Destge Progres Requiremente Organisational structure Beepenetb111ttee of organisation Techetcel informatise encheeses Document Centrol Deetsa dec ment esistenance and reteetten Management review Training Design inputo Dec eeet preparetten Quality levels, acceptance stam-dardo, recorde Deelse verification Audits Corrective action Esperience reperto Deetse chaeges 3.2 Deetse Input Reguiremente Perferesece requiremente (capacity, reting, systee output, othere)
Codes, standarde, and regulatory requiremente Deelse condittees (envireemental, leadfase, fluid cheatetry, voltage, othere)
Interface requireesete Material requiremente (including such itees se compatibility, electrical teoulattoo properties, coattage, and correstee reelstance) leechanical requiremento Structural requirements TM-35-6262/7 A-3
I ATT N A ,
ERpitJIATORY ATTRIBUIES NATR11 (Coettamed)
" " 12 VEL III LEVEL I 12VEi. II 3.0 Deelse Activity 3.2 Deelse Impet tegwiremente mydreolic requiremente (coattamed) (coattamed)
< Onestetty requiressets (tectedles provisions for sempting)
Electrieel regelresente Leyeet/Arreegement regelremente Operettoest regelresente moder verleue pleet condittene Instriementattee end control regelre-mente Acceselbility, in-service tospec-ties, and e M aletrative control regetromoete Redondency, diveretty, and separe-ties regoireseets Fe11ere effects requirements
- Test regelremente Fire protectice or resistence regelremente Processes, perto, and equipment settable for applicatise Safety regetressets (tectedlag radiettee besorde, materiale, escape provielene from encloeures, gromed-ing of electrieel systems)
Need11ms, eterage, and shipping requiremoete 9
TM-35-6262/7 A-4
i I s
f 1
- ATTACBE3rr A IIF1AIIATot? ATTRIBirFRS NATRIE i
l (Caettooed) i l 12 VEL 1 12 VEL II 12 VEL III i
3.0 Deelge Activity 3.3 Destga process Tramelettee of tapete i procedures Deelge sealysee Calculations Deelse outpute (drawlege, specifice-tiens, other)
Analysis /calculattee errore i
j 3.4 Interface Centrol Esternal (identification, reopenet-bility, commeicat tee, dec menta-I tion) i Internal (identificattee, reopenelb-111ty, ceamuelcettee, doceentation)
I j 3.5 Deelse Verification Selection and tecorporettee of
, lopets Description and reasonablenese of asemptions Specificettee of guelity and quality sacersace requiremente J
Identificattom of codes, etendards, and regulatory requiremente l
j Coseiderettee of constructios/ opera-l tiss esperience
.i Satisfaction of deelge interface i
- regelresente Deelge method appropriateness Reasonableness of output compared to
, impet l
Settability of specified parte, egetpmest, and processee 1
TM-85-6262/7 A-5 9
i i
i i
s l ATTACW err A i
=
EIPLAIIATORY ATTRIBerrES IIATRIE i
(Coettened) 4 i
IInteriale compatibility to other esterials, ese, sed deelse enviree-mental conditione 9
12 VEL 1 12 VEL II 12 VEL III 3.0 Deelse Activity 3.5 Deelse verification Provietee for in-service toepection 3 (costlamed) (caetfamed) accesetbility.
l Considerettee of radiation esposere Specificettee of teetles regelre-
- eente Specificettee of handling, storage, eleselos, sed shippies requiremento Specificaties of identification and d'
]
recorde regelresente j 3.6 Document Control
- Progres ,
Preparettee ,
~# \.
f Approval '
1..me-e Revietee ,
,s PSAR accuracy i ,
iN >
3.7 Design Cheese Control \ Test resulte ensatisfactory '
~. Interference *
.i ',
s *
, .N Feectional regelreamste' met met
~,
h s Dispeettise of eenconferemece ,
t., ,"
' Rewirement cheeses "t
' , Operatiesel esperience g Deelge leprovemente ,
s
- 'A \ ,
i . r 1 t
j ..,
I ,
i 1
1
. . - . . - ~ - - . - . . .
i l ATTM3mfr A EIPLamatest ATTatsWTES NATR11 i (Continese) l '
- 1,gwrL 3 tavsL 13 12vtL III
(
1 3.0 Seeign Activity 3.0 Cetrettive Actice Progree l (continued) Inputs Process Interface '
- Yerificetten j Document coetrol
- Change costrel j Procedures i
Personeel Training Management 3.9 Audits Pereennel j Internal I 1
External i i
Centrol I
Schedule 5
Results Pellem i
4.0 System. Structure, See DAP Tracking System Composeet Affetted Codes
{
i i
t t
4
'I 1 .
TN-85-426217 A-7 i
i i
i
- ATTAcastfr A
) O.
1 EErl.ANATot? ATTRIBWrES NATRIE
- i (Centlemed) 1 4
1.Evat 1 12751. 1I 12Wat. II1 l 5.0 Characteristica 5.1 Claselficaties Not closelfied of Isome Unsebetantiated
, Discrepeecy J ,
Observation Deviation Deficiency l Uncleastfied deviaties Progreemetic deficiency 5.2 States Opee l Closed i
i 5.3 Type ceneric Type-1 Isolated Cumulative 4 Not cumulative Type-2 Technical
! Progra m tic j
6.0 Potential Safety 6.1 Reported or fomed by DAP Reported by External Source Significance Found by DAP to be safety-eigelfi-
- cent ,
1 Found by DAP not to be safety-
, sigelficant i
6.2 Intended Safety Function RCS pressere boundary l Containment integrity
- Instrumentatton l
Control 4
Nechanical/ structural sug port I toergency power Isoletten boundary Accident prevention Accident mitigattoe i TM-85-6262/7 A-g
I LTTAmerf A
~ .
EXPLANAT0tf ATTRIBUTES NATRIX (Coettened) i i'
12 VEL 1 LEVEL II LEVEL III 6.0 Potential Safety 6.3 Type of loss of capability Boundary fatture .
Significance to perform Intended safety Loss of electrical pover/str/
(continued) function hydraulice Monitor failure Control failure Delivery of cooling medius Component support fatture Personnel protection Equipment protectice Structural failure Analysis indeterstaate to soeure capability 7.0 Root Cause 7.1 Procedures Ambiguous Incorrect application Incomplete Miesed technical requiremente Misunderstood regulatory require-ments/co m ete Missed regulatory requirements Inedequate review for require-mento/ commitments Out of date Monexistent Contradictory procedures Conflicting techetcal requiremente j
I TN-85-6262/7 A-9 a
l T ATTacasspr a -
EIFt.ANATORT ATTRIBIFFES NATRIE ,
(Contioned)
I 12Vtt I 12 VEL II 12VEi. III 7.0 toot Cause 7.2 Procedure Implementation Incessisteet (continued) Error la M gment Enoutag violation i Unknown violetton I Inadequate revleu that requiremente 1 met Staple mistake Procedure requirement met understood Imedequate input information Wroeg codes /standerde used Dieregarded procedure Failed to get inpute 7.3 Commuelcations Failure within group Fe11ere between groupe Imedequate between compostes 7.4 Imepection/ Audit Inadequate check 11ste Inadequate troising/qualificettoe Imedequate surveillance of inspec-tiene Imedega te seelyste of fladings Inadequate distributioe of findtage i Not done
) Escesetve deferre1/ backlog TM-85-6262/7 A-10 .
l ATTAODENT A
- EXPIANATot? ATTRIBUTES MATR11 .
j (Coetiewed) i l tzvrL I 12 VEL II LEvtL III 7.0 Root cause 7.5 Timelinese Imedequate time ellowed for task i
(continued)
Insufficient engineering done Inadequate to check changes against j requirements /ceanitoeste Untimely incorporation changes to
- requiremente/cometteents Failure to incorporate changes la requirements /comettoest e Umtimely audits /inspectione Severe schedule pressure 7.6 Documentation Failed to demonstrate compliance
!, Inadequate access to Saformation Illegible Missing Incomplete Misfiled Inaccurate 7.7 Training /Quellfication Inadequate for teeke performed (designers) Nonesistent Fall to retteln after errore l Inadequate qualification etendarde 7.8 Transfer of Information Correct inforestion used leproperly Incorrect !aformation transferred Ieproper interface Nomenteteet interface Inforestion not tremeterred TN-85-6262/7 A-11
v ATTACBENT A EXPLANATORY ATTRIBUTES MATR11
! (Coatisued) i
!I LEVEL I LEVEL II LEVEL 111 l
i 7.0 toot Cause 7.9 Flassed Management Risk i
(continued) 1 7.10 Foot-Inspection / Turnover Coetrolo
, 7.11 Corrective Action Fall to recognise program breakdown 4 Fall to identify root canoe Fall to prevent recurrence Fall to trend Fall to recognise recurrence l Inadequate to correct problem j Not implemented 1
. 7.12 Management Attestion Lack of goals / objectives Lack of intereet/indifferernce Inadequate for treede Inadequate staffing Fall to supervise
, Inadequate analysis of findings i Lack of perf ormance/ef fectiveness measuree Inadequate policy for performance of l
work Fall to implement policies Fall to assess policies l No oction on feedback received Flanned/soeumed risk Oversight li
- l 7.13 Randon Error (root cause 1
indeterminate)
I i
TN-85-6262/7 A-12 a
s ATTACa mfr A j EEP1JWIATORY ATTRI81FTES NATRIE -
(Coetteeed) ,
i I
LEVEL I 12 VEL II 12 VEL III 8.0 Fotential Ceneric S.1 Reported or foemd by DAP Reported by Enternal Source Implication Found by DAP to have generic implications Foemd by DAP not to have generic implications
- 8.2 Scope Affects one discipline Affects multiple disciplines 8.3 Indeterminate Results Analyste Quality of desige Quality of systems, structures, or componente (hardware) 8.4 Impact on Desige Program Inpute Process Interface Verification Doc eest control Change control Corrective action Audite 9.0 Nature of the Problem 9.1 Ferooneel Error (list of specific error) 9.2 Procedure Comteet Error i
9.3 Procedure Implenestation Error 9.4 Mesagement Control Error TM-85-6262/7 A-13 .
s ; '
LTTAQBert A EXPLANATORY ATTRIBUTES MATR11 *
(Coetinued) t.EvtL I 12 VEL 11 12 VEL III 9.0 Nature of the Problee 9.5 QA/QC Error i
9.6 Design Program Inadequacy I 9.7 Violation of codes, etendarde, requiremente, or commitmente 9.8 Computer Code Inedequacy 9.9 Analytical Method Inadequacy 9.10 Interpretation Error 9.11 Assumption Error 9.12 Calculation Error 9.13 Nordware Fe11ere 10.0 Review Topic (List number of Review Topic) -
(Croup of MDAe effected) 11.0 Affected NDA (List one or more effected NDA ambers) i i
{
j l
l TN-85-6262/7 A-14 '
ATTACHMENT B TREND EVALUATION I. PURPOSE To investigate whether a trend ' exists, to determine by evaluation and consensus decision-making whether any trend found is adverse with respect to the design of CPSES, and to document the evaluation on form DAP-7-1 in accordance with this attachment. Equivalent techniques for trend I evaluation as part of IRRs are authorized as an alternative to this attachment, provided they address the contents of this attachment and document a logical progression of facts and judgment that supports a conclusion in the IRR that a trend exists and whether it is adverse.
II. SCOPE O Limited to identification and evaluation of any trend that may exist within a set of discrepancies (identified as a result of implementing the self-initiated parts of the DSAPs) or External Source Issues with attributes selected from one or more of the categories below:
Design Discipline Design Organization Design Activities System, Structure, or Component '
Classification, Status, and Type Potential Safety Significance Root Cause Potential Generic Implication Nature of Problem Review Topic (Group of HDAs)
Homogeneous Design Activity (HDA)
- Discrepancy Numbers (if appropriate) l TN-85-6262/7 B-1 l
l
O III. METHOD OF REVIEW 1.0 Trend Identification 1.1 Select the attribute to be trended end attributes constrained in this evaluation and list them on form DAP-7-1. Any number of attributes may be constrained '
depending on the breadth of the search. Any combination of attributes may also be selected since the design activities from ANSI N.45.2.11 are considered not to be mutually exclusive. Attributes not constrained will cause all values (subattributes) of those attributes to be included in the resulting subset of DIRs.
1.2 Using information from DAP data systems (e.g., DAP
+
Tracking System, or other DAP files), perform the following steps as needed to determine the applicable subset of issue records and DIRs that reflect the l selected attributes.
1.3 Count the number of issue records /DIRs that are in the subset of issue records /DIRs, each of which exhibits the attributes constrained.
1.4 For the attribute to be trended (not constrained),
l determine the distribution of issue records /DIRs within each value of this attribute. ,
1.5 Count the number of DIRs in each value of the attribute (or Level II subattribute) within each distribution. Record these counts for each value of the unconstrained attribute, the issue records TN-85-6262/7 B-2 l
aa-Tmwm.,awm____a e-,--w ---www-,,ur e-sww-c-www w-yyw-y- e--e w. -g-vey- --g y -* w g-w 4 =e'-
(IR)/DIR numbers in the distribution, and the con-strained attributes that apply to each distribution.
Counts of DIRs may be recorded in computerized outputs (graphic and tabular).
Note: If a programmatic problem exists, there should be several ncn-duplicate irs /DIRs that reveal the same attributes because of the comprehensiveness of the DAP Phase 3 scope.
Although no absolute number of irs /DIRs can be defined as constituting a trend, the relative distribution of subattributes among ' irs /DIRs
~
should reveal that some subattributes apply to a much greater fraction of DIRs than other subattributes. The higher count subattributes in these relative distributions indicate trends.
_ Low-count subattributes in these relative distri-butions are likely to indicate an isolated error rather than a programmatic weakness; however, this assumption should be evaluated, confirmed, and documented either on form DAP-7-1 in the trend trend identification section or in a collective engineering evaluation done within the discipline in which these low-count subattributes are found to occur.
1.6 Review the descriptions of issue records /DIRs with the l
t higher count subattributes in each distribution.
l 1.7 If root causes have been . reported or identified, compara root causes of DIRs with the higher count subattributes.
1.8 Determine whether a logical relationship appears to exist among the DIRs with the higher count subattributes in each distribution. Try to determine
, whether a correlation and a causal relationship exist (i.e., discrepancies, etc., are similar.enough to have the same potential cause, attributes, or sub-attributes, that indicate the same problem).
TN-85-6262/7 B-3
~-
1.9 Identify any dissimilarities among the DIRs in the subset trended that show by contradiction that the discrepancies are not related, or that a trend does not exist.
1.10 Decide whether there are commonalities that indicate a trend.
1.11 Describe any trend.found in a new or existing primary l[
DIR (to be completed after trend evaluation) per DAP-
- 2. On form DAP-7-1, justify this determination, including the logical basis for the relationships among the discrepancies that make up the trend.
Alternatively, supporting documentation, that is equivalent to the above requirements, may be included in an IRR instead of on forn 7-1 although form 7-1 is still required, but with references to the sections in the IRR that address trend identification and trend d evaluation for safety significance. This description, in conjunction with the attributes listed on form DAP-7-1, shall characterize and justify the trend. The relationship between discrepancies could involve links such as a time period during which the errors ;
occurred, procedure, person performing the work, area of the plant, system involved, or type of component or commodity involved. Items such as these should be considered in identifying common attributes that link l discrepancies, and identifying trends.
1.12 If a trend is found, evaluate the trend per sections 2 ld I
(if the trend includes deviations), 3, and 4 below.
If no trend is found, close the trend evaluation per Section 4 of this Attachment. ld
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TM85-6262/7 ' -
B-4
1 2.0 Identified Trends containincr Deviations If trends identified contain one or more deviations, investigate whether similar deviations are likely to exist but have not yet been found.
2.1 Decide how to determine whether the deviation is likely to exist elsewhere. The method to make this determination may be to reuse an existing checklist or part of a checklist that is sufficient to detect the ,
deviation if it were to exist in the area being reviewed. Alternatively, the review may consist of
_- checking completed DAP checklists or engineering evaluations that would have detected the deviation elsewhere were it to exist. If a trend is found to exist based on available DAP documentation, there is
- no need to expand a review that would serve only as
! unnecessary confirmation of the trend that is already known.
2.2 Determine from project records (or "T" type DIRs that document some project records) whether deviations have been identified in the past.
similar l[
2.3 Based on the characteristics of the deviation being evaluated, determine whether, and if so, where else, the deviation was logically likely to have occurred.
Alternatively, use a process of elimination to exclude areas in which the deviation would not have been likely to exist or be safety-significant. Record this determination and a statement of its basis.
2.4 Decide what aspect of design activities should be examined in looking for other instances of the g ,
- 7. ,. ,,.
deviation if additional information is needed to
\.- .y.'
'_ "_'TN-N5'-6262/7 B-5
determine that a trend exists. This may be a review within the HDA, within a related HDA, or review topic in the discipline in which the deviation being ,
evaluated was found, or in other disciplines in which the deviation (due to its nature) could likely have existed as a safety-significant deficiency.
2.5 If Steps 2.1-2.4 above indicate that the deviation is likely to have existed elsewhere and additional reviews are necessary to confirm the trend, perform
, additional reviews of design activities or DAP records, and d'ocument the results. If other discrepancies are found, write DIRs per DAP-2, and determine whether these new discrepancies are part of the trend.
2.6 If an identified trend is to be "UNCIASSIFIED" its associated DIR is to be classified as an "UNCIASSIFIED TREND." No Trend Evaluation is required.
Root Cause and Generic Implication Evaluation is However, a d
required.
3.0 Trend Evaluation 3.1 Identify the programs, processes, procedures, work activities, methodologies, or other programmatic aspects that are potentially associated with the trend.
3.2 Evaluate these programmatic aspects to determine which ones are characteristic of the trend.
3.3 Review available results of DAP safety-significance evaluations or project evaluations that have been performed for any deviations included in the trend.
TN-85-6262/7 B-6 l
._ ._ _ _ _ _ _ __ . _ _ - - __ -- - - - - ~ -- ---
l
. l l
3.4 Develop information on whether the trend under evaluation would have been likely to have resulted in a safety-signficant deficiency. If so, describe the basis why any undetected deficiencies are likely to exist or are likely to be caused in the future. Since this determination relates to whether it appears that DAP deficiencies are likely to exist, not confirmation that they do exist, a DAP-22 sa l'ety-significance evaluation is not required, but may be performed on DIRs prior to a conclusion that a trend is adverse.
i 3.5 If one or more safety-significant deficiencies are believed to be likely to exist or be caused in future design work, then the trend should be proposed as adverse, and subject to a consensus decision as to its adversity by involved reviewers and DAP management.
., 3.6 Document determinations made in this part of the evaluation on form DAP-7-1, including review and approval signatures. If this determination is made as
, part of an IRR, form DAP-7-1 shall be completed, but may only reference an IRR that contains this infor-nation.
4.0 Conclusions of the Trend Evaluation 4.1 If the trend is determined by DAP consensus to be adverse (and thereby programmatic) write a primary DIR programmatic deficiency per DAP-2, and mark " Adverse Trend" on DAP-7-1.
4.2 If the trend is determined by DAP consensus to be programmatic but not adverse, write a primary DIR O TN-85-6262/7 B-7
a observation marked "Nonadverse Trend" per DAP-2, and mark "Non-adverse Trend" on DAP-7-1.
4.3 If the trend evaluation indicates that a trend does not exist, mark the "No Trend" box on form DAP-7-1, and do not write a primary DIR.
5.0 Review, Acoroval, and Documentation Sections 4.3 and 5.0 of the procedure part of DAP-7 apply.
O l
l I
l l
TN-85-6262/7 B-8 l
.-_ = - . __._ . - - - - , . - _ _ _ - . _ - . - - - - - - - . - - . - -
O ATTACHMENT C GENERIC IMPLICATIONS EVALUATION ENGINEERING EVALUATION I. PURPOSE To evaluate root cause or causal factors and generic implications (limiting boundaries of applicability) of programmatic deficiencies, unclassified deviations, unclassified trerids, and design deficiencies that appear to ld be discipline-specific or multi-disciplinary; and to i
document DAP activities and these conclusions.
II. SCOPE O Limited to identification and evaluation of any root cause or causal factors and generic implications of one or more programmatic deficiencies, design deficiencies, unclassifed trends, or unclassified deviations (hereafter referred to b ,
collectively as deficiencies) that appear to be discipline-specific (or multidisciplinary), and whose DAP Tracking System (DAPTS) numbers and Issue / Discrepancy titles shall be listed in the scope section of the evaluation.
III. OVERVIEW: METHOD AND EXTENT OF REVIEW 1.0 Describe the reason for conducting this engineering evaluation (e.g., identification or receipt of DIRs listed in the scope section that appear to affect only this discipline (or are multidisciplinary), direction from the DAP Manager to conduct an evaluation that TN-85-6262/7 ""C-1 I *i -
E
supports a multidisciplinary generic implications evaluation, or other reason for initiation).
2.0 Identify the design attributes that are relevant to this evaluation using the following steps:
2.1 List the attributes of the DIRs (primary issues and '
supporting DIRs contained in the primary issue) in -
scope in the following categories as appropriate (more than one attribute may apply to each category; if so, list multiple attributes in each category):
Design Discipline Design organization l Design Activities system, structure, or component classification, status, and Type Potential safety significance Roct Cause (if identified)
Potential Generic Implication (if identified)
Nature of Problem (e.g., technical issue from an IRR)
Review Topic ~(Group of HDAs)
Homogeneous Design Activity HDA) 2.2 Review Attachment'A, Explanatory Attributes Matrix, to determine whether additional Level II design attributes should be included and that the design attributes in the DIRs are accurate. If necessary, revise the listing in subsection 2.1 above, including any revisions of the DIRs to reflect corrected inter-pretations of design activities. ~
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2.3 of the attributes listed in Subsection 2.1, select those that appear to be relevant to evaluating generic implications; that is, determining root cause or causal factors, limiting boundaries of applicability (other HDAs, review ' topics, design activities, areas or items that are susceptible to the same condition) .
Some of these attributes may be contained in discipline-specific checklists. Upon completion of this evaluation, the attributes selected for the evaluation should characterize to the extent reasonable the what, where, when, why, who, and how of the DIR(s) . listed in scope. During the evaluation, attributes listed in scope may be revised, added or deleted.
l 3.0 Plan and document the method of evaluating the root :
l cause and generic implications. Include the following steps as written, or modify, revise, or delete any of them, or add other items and justify the changes.
l l
3.1 Review other information available that is relevant to the DIR(s) in scope that was not reviewed in Subsection 2 above, such as other DAP documentation.
, Document the extent and scope of these reviews.
3.2 Based on knowledge of the DIR(s) in scope gained by the above reviews, form a hypothesis of one or more root causes and limiting boundaries of applicability.
3.3 Determine what information or type of information is i
! needed to test the hypothesis (e.g., which attributes need to be evaluated within design activities, and what types of errors associated with these attributes I will prove or disprove the hypotheses).
TN-85-6262/7 C-3 I
l O
3.4 Identify the techniques to be used to gather this information (e.g., reuse of part of a discipline-specific checklist, interview, analysis of other DAP findings or documentation in the discipline (or multiple disciplines) including any applicable IRRs, review of project records, etc.)
3.5 Identify the sources of information to be reviewed to test the hypothesis (e.g., what records or system of records, what organization, group, person, review topic, IRR or HDA).
3.6 If additional reviews of design work are needed, select additional reviews that will test the hypothesis.
dp 3.7 Describe the planned approach to be used to l investigate and test the postulated root cause. Refer to Attachments D and E for more information that may 1
be helpful in evaluating potential root causes or causal factors. Use of these attachments is not mandatory - they are provided as potentially useful guides.
3.8 Describe the planned approach to be used to investigate and determine the postulated limiting boundaries of applicability. Include criteria for l accepting these boundaries (e.g., other areas likely to contain the unclassified deviation, unclassified trend, programmatic deficiency or design deficiency A under evaluation were checked and the deficiency was not found, other likely areas that had been previously evaluated in the DAP were reviewed and conditions of O TN-85-6262/7 C-4
the deficiency were not found, or due to the nature of the deficiency, it could not or is highly unlikely to , l 1
exist outside the postulated boundaries).
4.0 Collect objective evidence and gather information according to the plan in Subsection 3 above. This may include one or a combination of the following steps or '
other techniques described in the plan, or it may be unnecessary if root cause and generic implications are already evident.
4.1 Raview the DAP tracking system, Issues Records /DIR Reports, or other DAP documentation to determine which records are applicable within the scope of this evaluation.
Note: This generic implications evaluation may
) begin with only one deficiency, but it is possible that other records in the data will have I
attributes related to those of the deficiency.
i 4.2 Complete all or a portion of a DSAP checklist if the results of which will demonstrate whether the hypothe-sized generic imp 34. cation extends to activities.
- reviewed using the checklist. Document the acceptance criteria for any checklist used.
4.3 Develop information to be gathered by interviews or written responses, and conduct interviews or request written information. The purpose of interviews is to identify sources and types of information that are objective evidence on which the conclusions of this evaluation will be based. Written responses may contain objective evidence or only information on where to find ob.jective evidence.
O d TN-85-6262/7 C-5 i
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- O 4.4 Review appropriate project records or documentation (possibly but not limited to only "T" type DIRs) to determine whether the deficiency had been detected, ld evaluated, resolved or corrected in the past.
4.5 If a discipline-specific action plan does not encompass the activities needed to review generic implications of this deficiency, revise the DSAP, expand the scope of review, or justify that expanded scope is not required in an area of design that is undergoing reverification or redesign because the results of this design activity will accommodate-this review.
4.6 Document the information and objective evidence that was gathered or reviewed as part of this evaluation.
5.0 Investigate the hypothesized root cause or causal factors of the deficiency.
5.1 The investigation method used will be a systematic ap-proach that includes a logical flow of facts and relationships of conditions and events, develops and evaluates probable causes, and results in a conclusion of root causes or causal factors that is supported and justified. Attachments D and E contain examples of potential ' root causes or causal factors that may be appropriate, although use of Attachments D or E is not mandatory.
- 5.2 Based on the investigation in Subsection 5.1 above, determine the root cause or causal factors, which 4
O TN-85-6262/7 C-6
l l
I shall be based on a consensus of DAP technical personnel and management, including the Review Team Leader, DAP Manager, and appropriate discipline coordinators, discipline leaders, and reviewers.
5.3 If no root cause (or common cause, in the case of several individual issues that appear to be an adverse ,
trend) can be identified, document the investigation of root cause, and the result that a root cause could not be found, and therefore that the trend is not adverse.
6.0 Evaluate the postulated limiting boundaries of applicability of the deficiency. Based on the specific nature of the deficiency, use either deductive or inductive logic described below or a combination, as appropriate, to confirm limiting
, boundaries.
6.1 Using deductive logic, starting with a general hypothesis of limiting boundaries of the deficiency, i
review previous DAP reviews of design work outside the area in which the deficiency was identified, but where it would have been likely to exist as a safety-l siginificant deficiency. If this method is used, a conclusion that the deficiency does not exist elsewhere shall be based on the absence of finding safety-significant deficiencies in other potentially affected areas, or on revising the hypothesis and expanding the review to potentially affected areas until the deficiency which probably would have existed I
is no longer found.
TN-85-6262/7 C-7 l
i
l 6.2 Using. inductive logic, and starting with the specific instances in which the deficiency was found as the hypothesized limiting boundaries, based on engineering judgement that shall be documented, discard several or all other design activities or areas as potential ..
locations of a safety-significant deficiency. The basis for a conclusion using this approach is that the activities or areas discarded are unrelated to the nature of the deficiency being evaluated. The governing criterion for deciding that a deficiency is self-limiting to a given area is that it is unlikely that the same error could have resulted in a safety-significant deficiency outside of the identified area.
IV. BASES FOR DOCUMENTATION SELECTION
, DAP-8, Section 4.1.3 applies. This information is described in the appropriate parts of the generic l implications evaluation sections above.
V. SOURCE AND REFERENCE DOCUMENTATION DAP-8, Section 4.1.4 applies. This information, as described previously in the appropriate parts of the generic implications evaluation sections, will be documented in the steps in which it is used.
VI. ACCEPTANCE CRITERIA DAP-8, Section 4.1.5 applies. The criteria for accepting this engineering evaluation are as follows:
. TN-85-6262/7 C-8
o The generic implications of the deficiency in the scope of this evaluation were evaluated sufficiently to form a documented basis for acceptance or rejection w' of the hypothesized root cause.
o The generic implications of the deficiency were evaluated sufficiently to form a documented basis for acceptance or rejection of the hypothesized limiting boundaries of applicability.
VII. EVALUATION Conduct and document the evaluation in accordance with the Overview: Method and Extent of Review described in Section III of the engineering evaluation. If revisions of this section are found to be necessary during the evaluation, DAP-8, Section 5.0 applies, i
VII. RESULTS AND CONCLUSIONS Document the results, conclusions, and bases for conclusions of this generic implications evaluation.
i Review DAP-8, Section 4.1.7, and incorporate the items listed that are appropriate. In general, these should include the following:
l o Any additional discrepancies identified during this evaluation and that they are properly classified per DAP-2 as "D" type or "C" type DIRs; o
Confirmed that root cause were evaluated; or causal factors of the DIR(s) o confirmed limiting boundaries of applicability of the deficiency that were evaluated; o Any other open items; '
o Identification of issues that have been resolved.
TN-85-6262/7 C-9 t-
l l
IX. FORMAT
- 1. Organize this evaluation in the format specified in DAP-8, Section 4.3, except that the main' text of the evaluation is specified as indicated below.
i
- 2. Engineering Evaluation Cover Sheet.
- 3. Abstract. I j 4. Main text of the evaluation as follows:
o Reason for the evaluation (Section III.I);
I o Design attributes relevant to this evaluation O (Section III.2);
o Method of analysis (Section III.3);
o Collection of information (Section III.4);
o Root-cause investigation (Section III.5);
o Limiting boundaries of applicability (Section III.6);
i o Results and conclusions (section VIII). "
X. REVIEW, APPROVAL, AND DOCUMENTATION DAP-8, Sections 4.2 and 5.0 apply.
i 4
~
TN-85-6262/7 C-10
ATTACHMENT D O EXAMPLE LIST OF POTENTIAL ROOT CAUSES OR CAUSAL FACTORS I
This appendix is provided as nonmandatory guidance for investigations of root causes of programmatic deficiencies, design deficiencies, and unclassified deviations.
- 1. Procedures not adequately specific to control situa-tions actually encountered in performing tasks.
- 2. Personnel not adequately trained in the applicability of procedures available for the task.
- 3. Personnel did not adequately research requirements and commitments prior to developing procedures or perform-ing work.
- 4. Inadequate understanding of regulatory requirements or commitments.
- 5. Inadequate understanding of the required documentation
' to demonstrate compliance with regulatory requirements or commitments.
- 6. Lack of adequate system or administrative controls to ensure that licensing / regulatory commitments were
(
reflected in procedures or processes.
- 7. Inadequate communications within a function group (i.e., some people did work correctly while others did not).
- 8. Inadequate communications between functional groups (e.g., correct information was passed between groups but was used incorrectly, incorrect information passed between groups).
- 9. The deficiency resulted from a planned management-assumed risk.
- 10. Procedures used were incorrect for the application.
- 11. Procedures were incomplete or failed to incorporate all technical requirements.
- 12. Lack of adequate inspection checklists. '
O D-1
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ATTACHMENT D< n'
~' "~~(continued).
e d
- 13. Lack of adequate inspector qualification / training.
) f~ _. s
- 14. Engineering not sufficiently complete shen activity was performed.- '
~
s
- 15. Inadequate time allowed to perform task properly.
- 16. Error in judgement by qualified person. c'
- 17. Personnel performed task knowingly in violations of t
procedures.
- 18. Lack of adequate administrative controls to . ensure that procedural requirements were met.
- 19. Failed to identify root causes of previous deficien-cies.
- 20. Failed to take appropriate action to prevent recur-rence of deficiencies.
O 21. Inadequate management attiention to trends in deficien-cies or failure to trend deficiencies.
- 22. Inadequate surveillance of inspection activities.
. 23. Lack of adequate accessibility to documentation (design, construction, testing, or QA).
- 24. Inscrutability of documentation.
- 25. Lack of adequate system or administrative controls to l
ensure that changes in design, construction, testing, or QA activities were evaluated (timely) against licensing / regulatory commitments.
- 26. Lack of timeliness in identifying, submitting, or receiving approval for changes to licensing / regulatory commitments.
- 27. Lack of adequate post-inspection / turnover controls over hardware.
28.
Cannot determine a root cause (isolated error).
O l D-2
ATTACHMENT E EXAMPLE QUESTIONS FOR EVALUATION OF POTENTIAL ROOT CAUSES OR CAUSAL FACTORS This appendix is provided as nonmandatory guidance for root cause investigation checklists used for programmatic deficiencies, design deficiencies, and unclassified deviations.
YES No la. Was the deficiency a direct violation other regulatory requirements?
lb. Was the deficiency a direct noncom-pliance with licensing / regulatory commitments?
Ic. Was the deficiency a direct violation of project procedures?
- 2. Did a deficiency similar to that iden-tified_ occur previously?
. Did the NRCTRT or CPRT find multiple incidents of essentially the same l deficiency?
4a. If the deficiency was identified previously, was action identified to prevent recurrence?
4b. Was the corrective action adequate?
- 5. Was the identified corrective action i
actually implemented?
- 6. Was there adequate technical input ,
to the input?
- 7. Did the activity make correct use of j industry codes and standards?
l
- 8. Was the work conducted in accordance with procedures?
- 9. Did people involved (e.g., craft,
- inspectors, etc.) know how to obtain technical input?
O i-85-6262 E-1
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() ATTACHMENT E (continued)
- 10. Was there adequate internal communica-tion (i.e., within the group responsi-ble for the activity)?
- 11. Was there adequate external conmunica-tion (e.g., between TUGCO and GIBBS Hill and between TUGCO and NRC)?
- 12. Was information regarding previous occurrences available to personnel?
- 13. Were previous identical or similar occurrences trended?
i
- 14. Were people trained in the activities they performed?
- 15. Were changes to requirements iden-tified on a timely basis,?
- i. Was information required to perform the task available to personnel?
- 17. Was required information kept up to date?
- 18. Did a planned activity result in a degradation of the process in which the deficiency occurred?
- 19. Was the division of responsibility among participants clear? ____
l 10. Were audits or inspections conducted l on a timely basis? __, ,
l 21. Were there conflicting procedural requirements?
- 22. Were there conflicting technical requirements?
- 23. Were schedule pressures held to an acceptable level? _
( 62626 E-2
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ATTACHMENT E O (continued)
- 24. Were there adequate, up-to-date management policies to address the situations encountered in performance of the work? '
- 25. Were these policies adequately in-plemented?
- 26. Was there a feedback loop to allow information flow back to policy-makers regarding problems with policies?
- 27. .Did upper level management indivi-duals demonstrate an interest in lower level activities through personal involvement?
l
- 28. Were goals and objectives adequately l defined?
- 49. Were personnel performing tasks, that proved to be defective, ade-quately qualified for the work they were asked to perform?
i O '- 85-6262 E-3 l
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ATTACHMENT F Evaluation Number: DAP-TE- ---
COMANCHE PEAK ADEQUACY PROGRAM Rev.:
TREND EVALUATION Number of Sheets:
DAP Discipline:
TREND EVALUATION - LEVEL II Attribute or Technical Issue Trended: Date:
Other Attributes Selected (constrained).
Discipline List as appropriate:
Classification Generic Implication Design Organization Status Problem Design Activity Type Review Topic Activity Attribute Safety Significance HDA System /5tructure/ Comp. Root Cause DIR Nos.
Number of DIRs in This Subset:
Name of Each Subattribute in Trended Attribute /No. of DIRs/DIR Nos.
TREND DESCRIPTION Date:
iO Yes No Trend Identified Deviation included Additional Reviews Required Additional Reviews Completed (Describe in Attachment)
Discipline Specific Multidisciplinary TREND EVALUATION Programs Affected: Date:
Potential for Safety-Significant Deficiency:
Description and Bases of Evaluation:
i l
l inclusion: OAdver..Tr.na e ceo ew *.r i .e Ounei..eiri.aTr.na O won. aver.. Trena t *,,,, ein e.. m. ....i . ,
O wo Tr.ns Prepared by/Date / DAP Manager /Date /
Discipline Coordinator /Date / Approved by RTL/Date /
Dap Form 7-1 F-1 Rev. 2
ATTAL ENT G Discipline: -
COMANGE PEAK DESIGN ADEQUACY PROGRAM TREND EVALUATION LOG REVISION DATE CONTROL 1.D. NO. SUPERSEDED TRENDED ATTRIBUTE OR '
BY TECHNICAL ISSUE O I 2 3 4 S 6 t
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e FORM DAP-7 2 REV.I O '
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O ATTACHMENT H !
l
SUMMARY
OF DAP-7 TRENDING AND GENERIC IMPLICATIONS EVALUATIONS This summary is an overview of the DAP procedure on Trending and Generic Implications Evaluations, DAP-7, and the interrelationships among various evalu ations that are conducted on Discrepancy / Issue Resolution reports (DIRs) depending on their classification. This summary is intended to familiarize those DAP personnel not directly involved in trending and generic implications evaluations
, with these activities. Understanding the content of this summary should give those DAP personnel not directly involved with trend and generic implications evaluations sufficient knowledge of these activities, so that they do
, not need to read the other parts of DAP-7. Those DAP j personnel who will be doing trending and generic implica-tions evalutions within a specific discipline or across disciplines should read and' understand DAP-7 and its other attachments before conducting these types of evaluations.
Interrelationshius Figure 1 of DAP-7 (also included in this attachment) depicts the relationships among:
o DIR identification, evaluation, and clastifica-tion o Safety significance evaluation o Trend identification and evaluation TN-85-6262 H-1
o Root cause and generic implications evaluation o corrective action evaluation, and o closure The DAP procedures that apply to these activities are included in Figure 1.
All DIRs are eventually classified according to the DAP definitions, and all DIRs other than those found to be unsubstantiated or duplicate issues will - be included in trend evaluations. ,
safety significance evaluations are conducted on devia-tions, except for those deviations that are being addressed by proceeding directly to corrective action. These excep-tions, called unclassified deviations, are associated with designs undergoing redesign or reverification, such as piping and pipe supports, cable trays and supports, and conduit supports.
If the deviation is found to be safety-significant, it is classified as a deficiency and subject to evaluations of root 'cause, generic implications, and corrective action.
Even though the safety significance of unclassified deviations is not evaluated, DIRs with this classification also undergo evaluations of root cause, generic implica-tions, and corrective action.
In addition, if adverse trends are found (classified as programmatic deficiencies),
or unclassified trends, they too undergo cause, i
root generic implications, and corrective action evaluations. ld O .
TN-85-6262 H-2
Trend Evaluations O Trends may be initially identified based on information coded on the DIR form and entered in a data system for searches, sorts, and displays. This information is called Level II. The Level II information is explained in more detail (Level III), which is used to ensure proper selec-tion of Level II DIR attributes. If the distribution of DIRs in Level II attributes shows a concentration, the DIRs in that concentration are reviewed for accuracy and. to identify whether their charac teristics indicate a trend.
Jud'.gement on the part of personnel within DAP disciplines is also used to identify the existence of a trend.
Trends are evaluated to determine whether it is likely that existence of the trend could have resulted in the occur-rence of undetected (safety significant) deficiencies in the affected area of design. If it appears likely (based on a DAP-22 safety-significance evaluation or engineering judgement regarding final classification of DIRs within the discipline), then a trend is termed adverse, and a program-natic deficiency is created as a primary DIR. Trends j
determined not to be adverse are termed nonadverse, a DIR l
is written as an observation marked nonadverse, and no further evaluation of the trend is done in the DAP. If the trend is to be unclassified, a primary DIR is written and a b root cause/ generic implications evaluation is required.
All of the DIRs generated are transmitted (at an appro-prjata stage in the process) to the Comanche Peak Project organization.
If a trend contains any DIRs cl7ssified as deviations, then the DAP will consider additional reviews of design or completed DAP work to determine whether similar deviations exist in areas of design that could be affected. If a TN-85-6262 H-3
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trend contains only DIRs classified as observations, then l no additional reviews are called for.
k Individual trend evaluations are documented on a Trend Evaluation form and any attachments, such as continuations of various blocks on the form or computer- generated printouts of charts and tables. In each DAP discipline, one engineer ing evaluation will be written to summarize all trend evaluations in that discipline. The engineering evaluation will also establish a basis for concluding that a sufficient level of trending was completed in that i discipline.
l As trends may be specific to one discipline or multidisci-
'plinary in nature,- trend evaluations will be done~ both within specific DAP disciplines and across DAP disciplines.
Trend evaluations may be started on DIRs prior to their receiving final DAP classifications. Upon changes or final classifications, these trend evaluations will be updated and revised as necessary. Trend evaluations are approved by the DAP Review Team Leader.
Generic Inclications Evaluations Generic implications evaluations are used to investigate root causes or casual factors and to determine ~ limiting boundaries of applicability of certain classifi cations of DIRs. This evaluation applies to design deficiencies, programmatic deficiencies, unclassified deviations.
unclas 'fied trends, and ld The intent of this evaluation is to determine the attri-butes (or characteristics) of the design process or design control process that are associated with the deficiency, l stc., under evaluation. Some of these attributes may have TN-85-6262 H-4
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been identified in trend evaluations. Based on this knowledge, hypotheses are then formed as to potential root causes (or contributing causal factors) and potential boundaries of applicability of the deficiency. The method
! of testing these hypotheses is then developed and imple-mented. Additional' information, includ ing objective -
evidence, is gathered as needed from DAP or CPSES project l
sources.
The root cause or causal factors are determined based on consensus of DAP management and involved reviewers.
j Limiting boundaries of . applicability are then determined, j also based on consensus of DAP management and involved
! reviewers. During these determinations, it may become l necessary to revise the hypotheses and conduct other
, reviews to test them. If this occurs, iteration will continue, leading to the final consensus as to root causes j and limiting boundaries of applicability. The DAP Review Team Leader approves generic implications evaluations.
( Generic implications evaluations are documented in the i
, format of engineering evaluations. The results of these evaluations are also documented in the appropriate blocks
( of the DIRs to which they apply. Similar to trend evalua-tions, generic implications evaluations may be done within l
or across DAP disciplines, depending on whether root cause and limiting boundaries are limited by discipline.
TN-85-6262 H-5
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